| http://www.w3.org/ns/prov#value | - In this case, if the transfer from the U.S. plan to the U.K. plan was treated as a lump-sum distribution from the U.S. plan to the taxpayer rather than as a tax-free rollover, the distribution would be taxable in the United States, notwithstanding the fact that the taxpayer was a resident of the United Kingdom.
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